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6 Ohio opinions name it 1 courts 2015–2026 5 in the last five years
The cases below were cited by Ohio courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
State v. Byrnesgreen2 sentences2026Generally, “a trial court is free to expand the scope of a suppression hearing beyond the issues specified in the motion to suppress [1] so long as the matters within the expanded scope were material to the suppression sought, and [2] so long as the State had a reasonable opportunity to prepare itself for the hearing.” (Cleaned up.) State v. Byrnes, 2014-Ohio-1274, ¶ 12 (2d Dist.); accord State v. Tyson, 2015-Ohio-3530 , ¶ 35 (3d Dist.). {¶27} Henderson’s motion sought suppression of the bag’s contents. 2025While a trial court may expand the scope of a suppression hearing beyond the issues set forth in a suppression motion, it can only do so when “the matters within the expanded scope were material to the suppression sought, and so long as the State had a reasonable opportunity to prepare itself for the hearing.” State v. Fowler, 2016-Ohio-5940, ¶ 23 (5th Dist.), citing State v. Byrnes, 2014-Ohio-1274, ¶ 12 (2d Dist.), quoting State v. Blackburn, 1994 Ohio App. LEXIS 1171 , *4 (2d Dist. | 2 | 6 |
State v. Tysongreen1 sentence2026Generally, “a trial court is free to expand the scope of a suppression hearing beyond the issues specified in the motion to suppress [1] so long as the matters within the expanded scope were material to the suppression sought, and [2] so long as the State had a reasonable opportunity to prepare itself for the hearing.” (Cleaned up.) State v. Byrnes, 2014-Ohio-1274, ¶ 12 (2d Dist.); accord State v. Tyson, 2015-Ohio-3530 , ¶ 35 (3d Dist.). {¶27} Henderson’s motion sought suppression of the bag’s contents. | 1 | 1 |
State v. Fowlergreen1 sentence2025While a trial court may expand the scope of a suppression hearing beyond the issues set forth in a suppression motion, it can only do so when “the matters within the expanded scope were material to the suppression sought, and so long as the State had a reasonable opportunity to prepare itself for the hearing.” State v. Fowler, 2016-Ohio-5940, ¶ 23 (5th Dist.), citing State v. Byrnes, 2014-Ohio-1274, ¶ 12 (2d Dist.), quoting State v. Blackburn, 1994 Ohio App. LEXIS 1171 , *4 (2d Dist. | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Ohio. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
State v. Skeens
neutral
2 sentences2021State v. Skeens, 5th Dist. Tuscarawas No. 2017 AP 11 0030, 2018-Ohio-1610, ¶16 . 2021State v. Skeens, 5th Dist. Tuscarawas No. 2017 AP 11 0030, 2018-Ohio-1610, ¶16 . | 3 | 2021–2021 |
City of Dayton v. Dabney
green
2 sentences2021Montgomery No. 25860, 2014-Ohio-1274, ¶10 , quoting Dayton v. Dabney, 99 Ohio App.3d 32, 37 , 649 N.E.2d 1271 (2d Dist.1994), quoting Wallace at 219 . {¶30} However, a trial court may expand the scope of a suppression hearing beyond the issues specified by the defendant’s motion to suppress “so long as the matters within the expanded scope were material to the suppression sought, and so long as the State had a reasonable opportunity to prepare itself for the hearing.” Byrnes at ¶12. {¶31} If a trial court grants a motion to suppress based on an issue outside the expanded scope of the motion, t 2021Montgomery No. 25860, 2014-Ohio-1274, ¶10 , quoting Dayton v. Dabney, 99 Ohio App.3d 32, 37 , 649 N.E.2d 1271 (2d Dist.1994), quoting Wallace at 219 . {¶30} However, a trial court may expand the scope of a suppression hearing beyond the issues specified by the defendant’s motion to suppress “so long as the matters within the expanded scope were material to the suppression sought, and so long as the State had a reasonable opportunity to prepare itself for the hearing.” Byrnes at ¶12. {¶31} If a trial court grants a motion to suppress based on an issue outside the expanded scope of the motion, t | 3 | 2021–2021 |